Migration Advisory Committee review of financial requirements for family visas is published
The Migration Advisory Committee's (MAC's) review of the financial requirements for family visas, including the Minimum Income Requirement (MIR), has been published today.
You can download the 96-page document here or read it online here. All documents relating to the review can be accessed here on GOV.UK.
Importantly, the review recommends against the increase in the MIR to over £38,000 proposed under the previous Conservative government. The MIR is currently set at £29,000 and the previous government set out its intention to make two further increases by early 2025, firstly to £34,500 and then to £38,700, the same amount as the Skilled Worker (SW) route salary threshold. Home Secretary Yvette Cooper commissioned the MAC in September 2024 to review the policy, noting that the financial requirements are intended to maintain the economic wellbeing of the UK whilst respecting family life.
Recommending again the increase, the MAC states in its review: "The future MIR proposed under the previous government was equivalent to the SW salary threshold, which is currently £38,700. Given the Family route that we are reviewing has a completely different objective and purpose to the Work route, we do not understand the rationale for the threshold being set using this method. We do not recommend the approach based on the SW salary threshold as it is unrelated to the Family route and is the most likely to conflict with international law and obligations (e.g. Article 8)."
Overall in its review, the MAC acknowledges that there is no simple technical answer to setting financial requirements to neatly balance the UK's economic wellbeing with the right to family life. Any such decision involves complex social, ethical, and fiscal trade-offs. The review explores these trade-offs in detail.
The MAC considered four possible approaches to setting the MIR: by assessing standards of living, alignment with the welfare system, overall fiscal impact on public services, and comparisons to average earnings. While the Committee does not prescribe a definitive threshold, it identifies a reasonable range for the sponsor's income between £19,000 and £28,000 per year. Within that, most of the practical models — such as one based on working full-time at the National Living Wage — suggest a narrower band of £23,000 to £25,000. "A threshold at this level would allow most British workers in full-time minimum-wage jobs to qualify," the MAC says.
The Committee notes that setting the threshold higher may reduce net migration and lower any potential cost to taxpayers. However, it also warns that doing so could increase the number of families affected by separation and hardship. In contrast, a lower threshold would allow more families to reunite but might carry higher fiscal costs. Importantly, the MAC raises doubts about whether assessing only the sponsor's income provides a complete picture of a family's financial situation, and questions whether a higher income requirement would be consistent with the right to family life under Article 8 of the European Convention on Human Rights.
The review states: "If the government instead wishes to focus on the economic wellbeing of the country and seeks to reduce the overall burden of the route on taxpayers, we have highlighted how difficult it is to have a targeted approach to such an objective by placing an income requirement on the sponsor at a specific level in an attempt to reduce fiscally negative main applicants. In this case, the MIR will primarily function as a method of reducing overall numbers on the route and therefore reduce the aggregate fiscal cost. We cannot sensibly guide the government as to a net migration objective for the route, nor are we clear on whether such a policy is consistent with Article 8. The government could in essence choose any level for the MIR to achieve a predicted reduction in visas – but whether it does that by raising the MIR or capping the route and running a lottery does not fundamentally change what they are trying to achieve."
The review also highlights the serious personal consequences that the MIR can have, particularly on British children separated from one of their parents. The MAC expresses concern about the emotional and developmental impact of such separations and urges the Home Office to review its policies to minimise these outcomes wherever possible.
Professor Brian Bell, Chair of the MAC, said in the review's covering letter: "Our analysis and research show that the MIR can have significant negative impacts on families." In its review, the MAC highlights: "The impacts include stress and mental health problems caused by separation, as well as financial problems caused by the lack of support from the partner. The impacts on British children separated from one of their parents are particularly concerning. There is evidence of mental health problems among children, difficulty establishing meaningful parental relationships with the absent partner, and feelings of rejection."
The MAC continues: "More broadly, we think that the Home Office needs to review the situation of families with children, especially when they are applying out of country. We are not convinced that the current system sufficiently takes into account the negative impacts of separation on British children. In particular, we recommend a review of eligibility for the Parent route to consider making parents of British children eligible regardless of their relationship status. We cannot sensibly evaluate how many applicants this may impact and therefore what the potential change to net migration would be if such an approach were implemented."
Reunite Families UK, an NGO supporting and advocating for people affected by the financial requirements for family visas, said in response to the MAC report: "Today is a pivotal day for bi-national couples and families: for the first time people on the spouse/partner visa route were listened to by a Committee that wanted to learn what life is really like when you want to live in the UK … Reunite Families UK would like to thank the Migration Advisory Committee for the way it has conducted this review, by talking to people currently on this visa route and considering the human impacts of the rules - something that since their introduction in 2012 had never been properly considered."
The MAC's full recommendations are reproduced below:
Family Route: Financial Requirements Review
June 2025
MAC
MIGRATION ADVISORY COMMITTEE
[…]
Chapter 6: Recommendations
In this report we have reviewed the financial requirements for the Minimum Income Requirement (MIR), which has included an assessment of:
- Trends in the use of the Family route;
- Impacts on economic wellbeing and family life;
- Options to calculate the MIR;
- Any practicalities that should be considered; and,
- Exceptions to the financial requirements, including the adequate maintenance (AM) test.
As we have set out earlier in this report, it is important to note that, due to the limited evidence and numbers in certain Family visa categories, the analysis we have carried out and the recommendations we make focus primarily on partners. The Home Office should therefore give careful consideration to how the implementation of these recommendations may affect other sub-categories within the rules.
Our recommendations are summarised below.
MIR
Determining the MIR threshold involves striking a balance between economic wellbeing and family life. Whilst a lower threshold would favour family life and entail a higher net fiscal cost to the taxpayer, a higher threshold (below a certain level) would favour economic wellbeing, but a higher number of families would experience negative impacts relating to financial pressures, prolonged separation, relationships, adults' mental health and children's mental health and education. The decision about where the threshold should sit on this spectrum is ultimately a political and ethical decision the government must make.
In Chapter 3 we outlined four measures that could be used to calculate the MIR, alongside potential indicators for each measure. The measures included living standards and benefits thresholds, which are based on the economic wellbeing of the family, and fiscal impact and average income or earnings thresholds, which are based on the economic wellbeing of the UK. Whilst we do not recommend one specific measure, we do advise on the strengths and limitations of each measure and there are some approaches we recommend against entirely.
The current MIR is based on the UK earnings distribution, where the level of £29,000 is the 25th percentile of the earnings distribution for occupations that are eligible for the Skilled Worker (SW) route. The future MIR proposed under the previous government was equivalent to the SW salary threshold, which is currently £38,700. Given the Family route that we are reviewing has a completely different objective and purpose to the Work route, we do not understand the rationale for the threshold being set using this method. We do not recommend the approach based on the SW salary threshold as it is unrelated to the Family route and is the most likely to conflict with international law and obligations (e.g. Article 8).
At one end of the spectrum, having no requirement would fail to balance economic wellbeing and family life, as this would not take into consideration any impact of family migration on economic wellbeing. We also recommend against using the SW threshold on the basis that it is calculated with respect to a particular group of workers who are eligible for the SW route, whilst the Family route is open to all UK residents. If earnings related thresholds are used, they should be related to the overall earnings distribution. The SW threshold is also liable to change in future for reasons unrelated to the balance between economic wellbeing and family life – indeed this is the proposal contained in the recent Immigration White Paper.
Focusing on measures related to the economic situation of the family, a figure that exceeds the relative poverty threshold represents a plausible lower bound for the government to consider. Poverty is widely recognised as a significant negative outcome to be avoided. At the individual level, the gross relative poverty threshold is £17,000. However, we note that this threshold relies on the main applicant earning at least £8,400 after they arrive, to keep a two-person household out of relative poverty (the household threshold being £25,400). A more cautious approach to avoiding poverty would be to require the sponsor to have income that would be sufficient to keep the couple out of poverty even if the applicant does not work (£25,400). If the government is interested in a threshold that puts more weight on family life, the US policy requiring 125% of the relative poverty threshold at the individual level would represent a more cautious approach to reducing the risk of poverty (£21,200). In practice, this would be achievable with a single earner working 34 hours per week at the living wage.
If the government wants to use a living-standards approach that puts more emphasis on economic wellbeing and less on family life, indicators in the £24,000 to £28,000 range can also be justified.
It is worth noting, that despite being developed and calculated based on different rationales, a number of indicators (Universal Credit (UC) eligibility, poverty, National Living Wage (NLW), Real Living Wage (RLW)) fall in the 20th-40th percentiles of the income distribution. Additionally, some indicators would meet competing levels of economic wellbeing, e.g. a worker on the full time NLW (£23,800) or RLW (£24,900), would also achieve an income similar to the household poverty measure (£25,400). If the government wants to ensure families take responsibility for supporting themselves by requiring the sponsor to work but not necessarily requiring them to command a salary above the minimum wage, an MIR at this level would be appropriate (£23,000-£25,000). One benefit of the National Minimum Wage (NMW) is that it does not require value judgments or complex calculations to update the threshold; it is produced on a regular timetable using an established methodology.
If the government instead wishes to focus on the economic wellbeing of the country and seeks to reduce the overall burden of the route on taxpayers, we have highlighted how difficult it is to have a targeted approach to such an objective by placing an income requirement on the sponsor at a specific level in an attempt to reduce fiscally negative main applicants. In this case, the MIR will primarily function as a method of reducing overall numbers on the route and therefore reduce the aggregate fiscal cost. We cannot sensibly guide the government as to a net migration objective for the route, nor are we clear on whether such a policy is consistent with Article 8. The government could in essence choose any level for the MIR to achieve a predicted reduction in visas – but whether it does that by raising the MIR or capping the route and running a lottery does not fundamentally change what they are trying to achieve.
In practice, varying the threshold by region would create problems. Income differences are often larger within than across regions. It would also present operational challenges and could create unintended incentives for families to live/relocate into lower threshold areas. We recommend that the threshold should not vary by region. However, the government could consider setting the threshold at the UK excluding London value, where appropriate. This would make it easier to meet in London but would be fairer to the residents of the rest of the UK.
Finally, the government should note that the level of the MIR interacts with policies on the practicalities of meeting it. As noted earlier, the couple's finances are not known with any certainty; the government must thus choose how much confidence it requires that the family's income will continue at the same level in future (something it may be able to achieve by restricting the types of income that qualify or requiring a longer earnings history). If the government selects a higher MIR, it may decide that it is comfortable with a higher level of risk regarding future earnings (setting more liberal requirements on how couples can meet the threshold), and vice versa.
MIR practicalities
Should the entry threshold be at a household or individual level?
We recommend the Home Office explore options to consider UK job offers for main applicants. If it is concerned about risks of abuse, it could narrow the circumstances in which these job offers can be used, rather than preventing it for all applicants. If the Home Office decides to allow a job offer from main applicants to count toward the MIR, then the MIR level should be tested at the individual level if only one income is being used (with the applicant given a choice between the income of the sponsor or the applicant). If two incomes are being used, the MIR should be calculated at the household level.
The current policy does not account for a situation in which the sponsor (if overseas) or main applicant intends to remain in their current job and work remotely from the UK. Given the increase in remote working since the pandemic, we recommend that the Home Office reviews the rules to provide flexibility for sponsors or applicants to count employment income where it can be convincingly evidenced that the person will remain in their job and work remotely and will be taxable in the UK.
For in country applications (switchers and extensions) we recommend the MIR level should be tested at either the individual level if only one income is being used (with the applicant given a choice between the income of the sponsor or the applicant). If two incomes are being used, there is a stronger case for calculating the MIR at the household level, especially if the government chooses an MIR towards the lower end of the ranges identified above. This is more demanding than the current policy which allows applicants to use two incomes for an individual based test; however, the couple would still have the option of being tested against a single income at the lower level.
It will be important to monitor the impacts of any such changes. The Home Office should review the data collected on applicants to ensure that it is possible to monitor what applicants who are admitted based on a UK job offer or overseas remote work subsequently earn in the UK, by linking to HMRC data.
Should there be a separate value for child dependants?
Although children require additional resources and other countries have added an additional child component, families with child dependants are also most likely to be harmed by the MIR due to children being separated from one or both parents. We are not convinced the current system is working well for children, particularly those who are outside of the UK and separated from a parent inside of the UK. On balance, we do not recommend an additional value for families with child dependants. The Home Office should review all the arrangements as a whole to ensure that separation of children from parents is minimised where possible. In particular, the Home Office should review eligibility for the Parent route to consider making parents of British children eligible for the Parent route regardless of their relationship status.
Self-employment
Our evidence indicates that those who are self-employed find it difficult to meet the requirements. Reasons for this included a lack of ability to combine self-employment income with savings, the requirement to demonstrate 12 months' earnings instead of months (and from a fixed April-April point), and a delay between the end of a tax year and the filing of returns. On balance, we encourage the Home Office to review whether there are options to simplify the highly complex rules for self-employment income but recognise that this may be difficult in practice.
However, we do not see a strong rationale for preventing self-employment income from being combined with cash savings. The guidance in Appendix FM states that cash savings should not be counted in combination with self-employment income or employee earnings for people who must demonstrate 12 months of earnings rather than 6 (as described in Chapter 4), stating that this would not be an accurate indicator of the real level of resources available to the couple and would risk counting the same income twice. However, it is perfectly normal for cash savings to come from previous income, as was the case for most of those in the survey who used the savings route. The fact that the couple has not spent that previous income and was able to save it indicates a level of financial stability and provides a buffer in the event that their future earnings fall. We therefore recommend that it should be possible to combine cash savings with all earnings from employment and self-employment. There will need to be some consideration given as to how to avoid self- employed individuals borrowing cash from their business to meet the requirement, as this would not reflect financial stability.
What evidence of income should sponsors have to provide and how long before the application they have to have it?
Our evidence from the Call for Evidence (CfE) and qualitative research demonstrated that the requirement to provide payslips over a period of at least 6 months can cause difficulties for applicants and sponsors who are both living out of country. This requirement often requires the sponsor to move back to the UK in order accrue enough payslips, which can result in prolonged separation. Whilst we recognise that there is value in having a required period to evidence income and demonstrate labour market attachment, on balance, we do not believe it is proportionate to separate a parent who likely meets the MIR from their children for over 6 months, purely on the basis that they have not yet gathered a sufficient number of payslips. The Home Office should thus provide flexibility to enable families in this position to come to the UK together. It is up to the Home Office to determine how this should be implemented (e.g. as a formal change in the rules, through a change in Article 8 guidance, or by using visit visas). Additionally, we recommend that the Home Office simplify the rules for calculating income from employment over the 6-month period, replacing current practice with a calculation whereby the employment income received over the 6-month period is totalled and multiplied by 2 to get an annual amount. This should apply to both salaried and non-salaried employment.
Uprating
The most recent increase to the MIR was a large and unexpected increase for many potential applicants. Regularly updating the threshold is critical to ensure the policy maintains coherence: there is no point in setting a threshold that gradually decreases in real value over time, implicitly changing the balance between economic wellbeing and family life from the one the government initially decided. However, we are of the opinion that applicants must be given some forewarning and certainty. We therefore recommend that the government should announce the timing of the annual uprating and the new level at least one year in advance to ensure applicants can prepare.
AM & its practicalities
In Chapter 5 we outlined several issues with the design of the AM test that undermine its effectiveness in providing a fairer assessment for sponsors in more vulnerable circumstances, such as those with disabilities. One of the most critical issues is that the AM formula is now outdated because it is based on the amount of Income Support a family receives, even though Income Support is being phased out and replaced by UC in 2025/26.
Who should be eligible?
There is also a contradiction in terms of the types of benefit an applicant needs to be in receipt of in order to be eligible for the AM route. Although Carer's allowance (AM qualifying) and Carer's entitlement have identical criteria in terms of caring responsibilities, Carer's allowance is also means tested (applicants must earn <£196). In practice this means that sponsors receiving Carer's entitlement could choose to stop working to lower their income below the level needed to claim Carer's allowance and therefore be eligible for the AM test. We recommend that the Home Office should work with the Department for Work and Pensions (DWP) to ensure the list of eligible benefits is appropriate.
Outline whether there is a choice for individuals to meet AM or MIR
The current AM policy does not allow applicants to choose whether to be assessed against the MIR or AM, if they are eligible for AM this is the route they must use. We see no reason that they should not be allowed to meet the MIR if they are in a position to do so. Therefore, we recommend that sponsors who are eligible for the AM test should be able to choose to meet MIR if they prefer. Note that this will no longer be needed if the government removes the financial element of AM. We do not recommend that the AM test should be available more broadly.
Alternative options
We presented four alternative options to the AM test and outlined their strengths and limitations, these options included replacing income support with UC (Option 1), the poverty income threshold (Option 2), the minimum possible UC payment (Option 3), and having no financial test for qualifying individuals but retain the existing adequate accommodation requirement (Option 4). The fourth option seems to be most transparent and should in theory not make much difference to the number of people who qualify. Retaining the accommodation section of the test ensures that applicants to the route have sufficient accommodation for their entire family unit.
Data recommendations
Throughout the process of undertaking this review, we were surprised at the lack of data that is collected by the Home Office in a consistent manner which would enable analysis of how the Family visa is working. This has not improved since the MAC review in 2011 on the Family visa. For example, whether an application is subject to the MIR or AM test and the sponsor's income are typically recorded by caseworkers in case notes, rather than in a consistent format. This means that one must rely on relatively small samples of case notes to analyse sponsor income or other sources used to meet the threshold, rather than data that covers all applications in the route. We appreciate the Home Office providing us with samples of data to analyse for this review but suggest that simple changes could be made to ensure data is collected in a consistent format and to enable ongoing robust analysis across the route. For example, collecting data through standardised forms rather than through individual case notes. Currently the Home Office does not collect data on a range of information which is crucial to effectively monitor and evaluate the impacts of the Family visa. This includes:
- Whether the application is subject to the MIR or AM test, which makes it difficult to understand precisely how many people are using this route and refusal rates;
- Reason for refusal or decision to place an applicant onto the 10-year route, which makes it difficult to understand the impact of a change in the MIR;
- The breakdown of sources of finances used to meet the income requirement (benefits, savings, salary, other), income levels, and whose income was used (applicant, sponsor, both), which makes it difficult to estimate the potential impact of any changes in the MIR levels;
- Any information on the sponsor, again making it difficult to understand the impact of a change in the MIR (age, earnings, gender);
- Location, which we understand is recorded by case workers but isn't available for use in any datasets; this makes it difficult to understand the impact of changes to the MIR by region;
- Whether fee waivers had been used;
- If being tested using the AM, which disability benefit the individual received; and,
- The range of case types (sub-categories of the Family visa route) used for the Home Office Management Information within the Family visa category is relatively complex, and in some cases do not necessarily align with published statistics particularly for in country visas. Simplifying these for use in statistical analysis and mapping them to published statistics categories may support further analysis of routes, such as child dependants and adult dependent relatives.
We recommend that the Home Office review and update management information for the Family visa route so it is possible to effectively evaluate the impact of the route, and monitor the effect of rules changes to the route in the future. Key characteristics from this updated management information should be included in the matched HMRC data. For example, if the Home Office accepts our recommendation to make more applicant job offers eligible to meet the threshold, it will be important to collect the data that will be required to ensure that these job offers reflect what the applicant ultimately earns, and that this income is sustained over reasonable periods of time. Rather than simply assuming that job offers made to foreign nationals are less reliable than job offers made to British citizens, it could pilot options to consider applicant income and then actually measure whether this is true. The Home Office should also link sponsor and main applicant data from HMRC so that it is possible in future to monitor household income. This could be done during the application stage where evidence of sponsor income is already checked and therefore it should be simple to collect the National Insurance number in a consistent way.